The most expensive compliance problem in healthcare construction is the one discovered after the building is complete.

Every healthcare construction project progresses through three critical design phases: Schematic Design (SD), Design Development (DD), and Construction Documents (CD). Decisions made during each phase directly influence whether the organization will achieve a successful occupancy, licensure approval, accreditation survey outcome, CMS certification, and ultimately reimbursement.

When accreditation and regulatory compliance experts are integrated into each phase, organizations gain the opportunity to identify risks early, when changes can still be made on paper rather than through costly construction rework.

Schematic Design (SD): Evaluating the Concept Before It Becomes a Problem

The Schematic Design phase establishes the overall framework for how care will be delivered in the new facility. This is the organization’s first opportunity to ensure the design supports regulatory compliance, accreditation requirements, and future survey readiness.

During the SD review, accreditation and regulatory experts evaluate:

• Overall department adjacencies and patient flow
• Clinical program space requirements
• Preliminary life safety concepts
• Occupancy classifications
• Fire and smoke compartment strategies
• Means of egress concepts
• Behavioral health safety considerations
• Infection prevention design concepts
• Environment of Care requirements
• Emergency management considerations
• Preliminary Safety Risk Assessment (SRA)
• Preliminary Infection Control Risk Assessment (ICRA)
• Interim Life Safety Measures (ILSM) planning requirements
• CMS Conditions of Participation implications
• State licensing requirements
• Accreditation standards applicability
• FGI Guidelines compliance

Examples of issues commonly identified during SD include:

• Inadequate smoke compartment configurations
• Improper department adjacencies creating workflow risks
• Behavioral health ligature risks
• Lack of required support spaces
• Improper patient observation capabilities
• Insufficient emergency egress strategies
• Infection prevention concerns related to unit design

Identifying these issues during SD often prevents significant redesign efforts later in the project.

Design Development (DD): Testing Compliance Against Real Operations

By the Design Development phase, concepts have evolved into more detailed room layouts, workflows, infrastructure plans, and operational relationships.

This is where accreditation, regulatory and compliance experts begin evaluating whether the building will actually support compliant patient care.

During DD reviews, accreditation and regulatory consultants evaluate:

• Detailed room layouts
• Clinical workflows
• Staff workflows
• Patient movement patterns
• Equipment locations and clearances
• Medication management support areas
• Clean and soiled workflow separation
• Infection prevention controls
• Utility and support room requirements
• Emergency response workflows
• Environment of Care requirements
• Life Safety Code compliance
• Updated SRA, ICRA, PCRA, and ILSM assessments
• Accessibility requirements
• Accreditation survey readiness implications

Examples of issues frequently identified during DD include:

• Medication room workflow deficiencies
• Cross-contamination risks between clean and soiled workflows
• Inadequate hand hygiene station placement
• Equipment placement conflicts
• Staff observation challenges
• Patient privacy concerns
• Emergency equipment access limitations
• Support space deficiencies

These issues are often operational in nature and may not be recognized by design professionals who are not familiar with survey expectations and real-world clinical operations.

Construction Documents (CD): Final Compliance Validation Before Construction

Construction Documents represent the final opportunity to validate compliance before the building is constructed.

At this stage, accreditation and regulatory experts perform a comprehensive review of final drawings and specifications to confirm alignment with regulatory and accreditation requirements.

Areas evaluated include:

• Final Life Safety Code compliance
• NFPA 99 and NFPA 101 requirements
• FGI Guidelines compliance
• K-Tag implications
• Fire-rated construction details
• Smoke barrier details
• Fire and smoke damper requirements
• Door ratings and hardware
• Medical gas infrastructure
• Utility system requirements
• Emergency power provisions
• Accessibility compliance
• Infection prevention infrastructure
• Environmental controls
• Final Safety Risk Assessment validation
• Final Infection Control Risk Assessment validation
• PCRA and ILSM requirements
• Survey readiness implications of final design decisions

Examples of deficiencies frequently identified during CD reviews include:

• Missing fire-rated assemblies
• Improper barrier construction details
• Inadequate damper access
• Utility room design conflicts
• Medical gas compliance concerns
• Equipment clearance issues
• Inaccurate life safety drawings
• Environmental control deficiencies
• Design features that could create future accreditation findings

By the time construction begins, every compliance-related issue should already be identified, evaluated, and addressed.

Why This Matters

Organizations often view accreditation and regulatory compliance as a survey preparation activity. In reality, survey outcomes are largely determined during design.

When compliance experts participate throughout SD, DD, and CD reviews, organizations can:

• Reduce change orders
• Avoid costly redesigns
• Protect construction schedules
• Support timely occupancy
• Improve licensure readiness
• Accelerate accreditation and CMS certification activities
• Protect reimbursement
• Create safer environments for patients and staff

The most successful healthcare facilities are not merely designed for construction. They are designed for occupancy, licensure, accreditation, CMS certification, and long-term operational success.

Before the first wall is built, make sure compliance is built into the design. Barrins & Associates helps healthcare organizations integrate accreditation and regulatory compliance into Schematic Design, Design Development, and Construction Document reviews—helping prevent costly change orders, construction delays, occupancy setbacks, and survey deficiencies.

If a new build or major renovation is in your future, let Barrins help you design a facility that is ready for occupancy, licensure, accreditation, CMS certification, and reimbursement from opening day forward.

Barrins & Associates & Healthcare Building Solutions – “Aligning Design, Operations, and Compliance for Successful Openings.”